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2 Disclaimer The discussion in this document is intended solely as guidance. The statutory provisions and regulations of the U.S. Environmental Protection Agency (EPA) described in this document contain legally binding requirements. This document is not a regulation itself, nor does it change or substitute for those provisions and regulations. Thus, this document does not impose legally binding requirements on EPA, states or the regulated community. This document does not confer legal rights or impose legal obligations upon any member of the public. While EPA has made every effort to ensure the accuracy of the discussion in this document, the obligations of the regulated community are determined by statutes, regulations or other legally binding requirements. In the event of a conflict between the discussion in this document and any statute or regulation, this document would not be controlling. The general descriptions provided here reflect EPA's current views and may not apply to particular situations based upon the circumstances. Interested parties are free to raise questions and objections about the substance of this guidance and the appropriateness of the application of this guidance to a particular situation. EPA and other decision makers retain the discretion to adopt approaches on a case-by-case basis that differ from those described in this document where appropriate. Mention of trade names or commercial products does not constitute an endorsement or recommendation for their use. This document may be revised periodically without public notice. EPA welcomes public input on this document at any time. DRAFT August 26, 2010

5 1. INTRODUCTION 1.1 About this Best Management Practices (BMP) Guidance Document The U.S. Environmental Protection Agency (EPA) conducted outreach and identified that there is near-universal interest from stakeholders to better manage unused pharmaceuticals at health care facilities, as well as general interest in EPA s guidance on managing unused pharmaceuticals. This guidance document describes Best Management Practices (BMPs) that EPA recommends to health care facilities, such as hospitals, long-term care facilities, medical clinics, and doctors offices, when managing and disposing of unused pharmaceuticals. Environmental managers at health care facilities can use these BMPs to minimize sewer disposal of pharmaceuticals and properly manage unused pharmaceuticals. EPA s goal is to keep pharmaceuticals out of U.S. waters. EPA identified these BMPs after site visits at 12 health care facilities 1 ; consulting with over 700 stakeholders including health care professionals, government entities, health care industry associations, and unused pharmaceutical management companies; review of disposal data from 20 hospitals and long-term care facilities; and review of literature data, reports, and state recommendations. These practices are a combination of recommended and implemented practices with the goal of proper unused pharmaceutical management and disposal. This document presents the steps that environmental managers of health care facilities can take to identify and properly manage unused pharmaceuticals. The steps include: Conduct an inventory of pharmaceuticals and unused pharmaceuticals to quantify the amount of medication the facility is disposing of. Reduce unused pharmaceuticals by reviewing purchasing practices, using limited dose or unit dose dispensing, replacing pharmaceutical samples with vouchers, and performing ongoing inventory control and stock rotation. Properly manage unused pharmaceuticals by identifying types of pharmaceuticals and any federal and state requirements; when possible: reusing or donating unused pharmaceuticals, returning them to the pharmacy; sending them to a reverse distributor for credit and proper disposal; and using EPA recommended practices to dispose of pharmaceutical waste at the facility. Segregate waste for disposal to ensure regulations are met and to reduce costs (e.g., nonhazardous pharmaceutical waste disposal in a solid waste landfill may be less expensive than disposal via hazardous waste hauler). Train staff in proper disposal methods. This document also provides a list of other resources, such as EPA and industry association websites, list of current state repository programs 2, sample unused pharmaceutical tracking sheet, and considerations when contracting with a specialty waste hauler. 1 EPA also visited a long-term care pharmacy, waste management vendor, and reverse distributor. 2 Current as of DRAFT 1 August 26, 2010

6 1.2 Background To date, scientists have identified numerous pharmaceutical compounds at discernable concentrations in our nation s rivers, lakes, streams and drinking waters. As a result, the U.S. Environmental Protection Agency (EPA) initiated a study on unused pharmaceutical disposal practices at health care facilities. While EPA understands that there are many factors influencing the handling and disposal of pharmaceuticals by the health care industry, the focus of this study was on disposal to sewers. EPA decided to study medical facilities because the Agency believes that these facilities dispose large quantities of unused pharmaceuticals to sewers. Unused pharmaceuticals are dispensed prescriptions that patients do not use and medications that have expired. The term "unused pharmaceuticals" does not include excreted pharmaceuticals. Another source of unused pharmaceuticals is residue in used and partially-used dispensers, containers, and devices. Health care facilities may dispose of unused pharmaceuticals, especially residues, down the drain (e.g., intravenous (IV) bags emptied into the sink). For many years, a standard disposal practice at many health care facilities was to flush unused pharmaceuticals down the toilet or drain. EPA believes that facilities should not dispose of their pharmaceuticals down the drain. Pharmaceutical chemicals are also biologically excreted following patient use of drugs. Excretion is not addressed in this guidance. DRAFT 2 August 26, 2010

7 2. CONDUCT AN INVENTORY OF PHARMACEUTICALS AND UNUSED PHARMACEUTICALS How many waste streams are generated? Before a facility can identify the best means for reducing waste and disposing of the waste, it must understand what the facility is throwing out. This section will help facilities to determine the unused pharmaceuticals being generated and disposed of. EPA recommends that facilities take two steps to understand their unused pharmaceutical generation: 1. Develop a list of pharmaceuticals used at the facility. 2. Identify the unused pharmaceuticals generated and how they are currently managed. 2.1 Develop a List of Pharmaceuticals Used at The Facility The first step in managing unused pharmaceuticals at health care facilities is to identify the types of pharmaceuticals that the facility uses. EPA recommends starting either at the on-site pharmacy or by contacting the pharmaceutical supplier. Most hospital pharmacies maintain a formulary a list of pharmaceuticals approved for prescriptions to patients by attending physicians. The hospital pharmacy may also purchase pharmaceuticals not listed in the formulary to meet special circumstances. For this reason, purchasing records will provide a more complete list of what the pharmacy has in stock than the approved formulary alone. EPA suggests reviewing a 12-month summary of purchasing records. This initial review will assist the facility to most accurately categorize the unused pharmaceuticals. To develop a list of pharmaceuticals used at the facility, find the following information for all of the pharmaceuticals administered at the facility: National drug code (NDC); Brand name; Generic name; Manufacturer; Dosage(s); Form (i.e., liquid, tablet, cream, etc) different forms of the same medication may expire more quickly or remain in stock longer; and Package size. Using the list of pharmaceuticals prescribed at the facility, next determine how often those pharmaceuticals become waste. Once wasted pharmaceuticals are identified, the facility can use the BMPs recommended in Section 3 to reduce waste. 3 In addition, by knowing what is being disposed of, the facility can reduce its disposal costs by finding ways to reduce waste. Also, the facility could reduce purchasing costs by reducing the pharmacy s inventory of drugs that are identified as often being disposed. 3 Some health care facilities conduct their own inventory; others hire commercial services that have expertise in cataloging inventories and find that this is cost effective and less burdensome on existing staff. DRAFT 3 August 26, 2010

8 2.2 Identify the Unused Pharmaceuticals Generated and How They Are Currently Managed After the facility has a comprehensive list of the pharmaceuticals used, the next step in developing a waste management program is to identify the unused pharmaceuticals generated. Unused pharmaceuticals may be generated at numerous locations throughout the facility, for example at the pharmacy or on the nursing floor. At all possible waste locations, the facility should keep track of the following: Pharmaceutical identification (see list in Section 2.1), including any manufacturer samples that need to be disposed. A good initial step is to document the amount and frequency of outdated (expired) samples or stock per out-patient clinic or medical practice area. Reason for waste generation. At the pharmacy, reasons include expiration prior to use or spills. On the nursing floor, reasons include patient refusing medication, medication left behind when a patient leaves, or stopping of IV mid-stream. Where the waste goes. For example, the facility might currently throw pharmaceuticals away in the trash, collect them for other disposal, drain them in the sink, or flush them down the toilet. EPA recommends that the facility keep track of the unused pharmaceuticals for two weeks to one month. This time period may differ depending on the variety and frequency of services that the facility provides. Seasonality may also play a role in the types and quantities of pharmaceuticals being used. For example, the length of time depends upon how often doctors offices dispose of expired pharmaceutical stock and samples, how often hospitals check their crash carts for expired medications, or how often long-term care facilities check their emergency kits for expired medications. Once the facility has the list of discarded pharmaceuticals, it can identify commonly wasted pharmaceuticals and identify reasons for the waste generation. Then, the facility can use the BMPs provided in Section 3 to reduce the amount wasted. See Appendix B of this document for a Sample Unused Pharmaceutical Tracking Sheet. DRAFT 4 August 26, 2010

9 3. REDUCING OR AVOIDING UNUSED PHARMACEUTICALS How can a health care facility reduce unused pharmaceuticals? The simplest and least expensive way to minimize pharmaceutical disposal is to reduce and avoid generating unused pharmaceuticals. During outreach activities, EPA heard many facilities give examples of the cost savings from smart pharmaceutical management. Buying medicine in smaller quantities means fewer expire. By using vouchers from pharmaceutical sales representatives instead of using free sample pharmaceuticals, facilities can eliminate an entire waste stream. This section walks through how many health care facilities have reduced their waste and cut costs at the same time. After completing a waste review as described in Section 2, the facility can determine the pharmaceuticals commonly wasted and the reasons. Depending on the reason for the waste generation, it can use the BMPs in this section to reduce waste. Typical reasons why pharmaceuticals become waste include the following: Purchased medications expire before they are used; Patient refuses the medication; Pharmaceutical sales representatives leave samples that expire before they are used; Patient dies or is transferred; Patient has an adverse reaction, or is successfully treated, and stops medication; and Dispensing or other medication error occurs. 3.1 Review Purchasing Practices Once the unused pharmaceutical profile is completed, the facility should review purchasing practices to determine ways to reduce waste. The review includes: Identify any pharmaceuticals that commonly expire before use buy less to reduce wasted amount. Identify pharmaceuticals used by multiple departments purchasing a standard package size, dose, or form can reduce waste. This allows multiple departments to use the same supply. Example: Using the same dosage form for medications used in different departments of a hospital can facilitate stock rotation. For example, Hennepin County Medical Center (HCMC) in Minnesota was using 15-gram glucose (dextrose) gel tubes in its crash boxes. It was also dispensing 45-gram tubes to diabetic patients. The facility s Diabetics Committee recommends 30-gram doses; therefore a portion of the 45-gram tubes went unused. The facility switched all departments to 15-gram glucose gel tubes and was able to rotate short-dated tubes from crash boxes to departments with higher usage, potentially eliminating waste. 4 4 Reference: Minnesota Technical Assistance Program (MnTAP). Reducing pharmaceutical waste from patient-care settings. DRAFT 5 August 26, 2010

10 3.2 Order Smaller Container Sizes or Emphasize Unit Dose Dispensing Dispensed pharmaceuticals may go unused for a variety of reasons: patient refuses the medication, medicine is no longer needed or not effective, treatment or dosage changes, or patient is discharged. To reduce the quantity of unused pharmaceuticals, facilities may want to limit the number of doses dispensed to a patient at one time (unit dose packaging), use trial prescriptions or samples to determine medication effectiveness before writing a full prescription, and use smaller containers of pharmaceuticals at the pharmacy and on nursing floors Unit Dose Dispensing The facility can purchase prepackaged unit doses, for example, in blister packs or bingo cards. It can also prepare unit doses at the on-site pharmacy for dispensing to patients (e.g., individually wrapped or dispensed via an automated dispensing system). By limiting the amount of medication dispensed to a patient at one time, unopened pharmaceuticals can more readily be restocked and reused. As long as the packaging is not opened and has been stored properly, the facility may be able to return medications to its pharmacy for reuse (i.e., prescribed to another patient). Reuse of unit doses to another patient is often possible at hospitals, but not always possible for facilities with off-site pharmacies, such as long-term care facilities. However, even if it is not possible for a medication to be dispensed to another patient, an off-site pharmacy will usually accept the return of the unused medications (excluding controlled substances) and dispose of them for the facility. Example: At the Walter Reed Army Medical Center in Washington, DC, approximately 99 percent of the pharmaceuticals are dispensed as unit doses to reduce waste. The majority of unit doses are blister packs purchased from the manufacturer as unit doses. Other unit doses are packaged at the on-site pharmacy. For example, liquid medications are dispensed in 5, 15, and 30 milliliter (ml) doses Ordering Smaller Container Sizes If a health care facility finds that portions of bottled liquid pharmaceuticals are going unused and require disposal, it may be able to purchase smaller bottles of liquid pharmaceuticals and reduce the amount wasted. Using smaller container sizes and reducing waste has the additional benefit of reducing the purchasing costs related to the pharmaceutical. Example: The Marshfield Clinic in Wisconsin uses lidocaine in small amounts. Rather than purchasing lidocaine in 50 milliliter (ml) bottles that need to be discarded 30 days after opening, the clinic began purchasing 15 ml vials or smaller to minimize wasted medication. This change also reduced the purchasing costs for lidocaine Trial Prescriptions Certain medications have high incidences of side effects, and patients frequently stop taking the medication before the dispensed quantity is used. For these medications, EPA recommends that pharmacies use trial prescriptions in which only a small quantity (e.g., 7 to 14 day supply) is dispensed. If the patient stops taking the medication, the unused amount is reduced. DRAFT 6 August 26, 2010

11 Title III of the Affordable Care Act (2010) includes Section 3310, Reducing wasteful dispensing of outpatient prescription drugs in long-term care facilities under prescription drug plans and MA-PD (Medicare Advantage Prescription Drug) plans. This section limits the number of days (no more than 7) that a long-term care facility can provide prescription supplies to residents. This amendment takes effect January 1, Example: MaineCare, the Medicaid health insurance program managed by the Maine Department of Health and Human Services, instituted a new 15-day limit on initial prescriptions for certain medications they identified as having high rate of waste. These are medications that have high side effect profiles, high discontinuation rates, or require frequent dose adjustments. In addition to reducing wasted medication, MaineCare s policy aims to control health care costs. 3.3 Replace Pharmaceutical Samples with Vouchers Pharmaceutical sales representatives often provide sample medications to health care facilities. These samples can then be provided to patients at no cost as trial prescriptions. The use of sample medications is more common at doctors offices and clinics than at hospitals and longterm care facilities. If the samples expire prior to use, the health care facility must properly dispose of the unused pharmaceuticals. To reduce waste, EPA recommends that health care facilities replace the use of samples with manufacturer vouchers which the patient takes to the pharmacy for a free sample. This minimizes generation of waste from expired sample medications. Another approach is to accept only samples of the pharmaceuticals most frequently prescribed in each clinic. Example: The Marshfield Clinic in Wisconsin discourages their individual offices and clinics from accepting samples from pharmaceutical manufacturing company representatives. Instead, clinics and doctors offices provide their patients with vouchers, which the patients take to a retail pharmacy for a free sample. If the pharmaceutical manufacturing company does not have a voucher system in place, Marshfield Clinic requires that the company representative remove the samples from the clinic before their expiration date. 3.4 On-Going Waste Reduction/Avoidance Practices: Inventory Control and Stock Rotation On-Going Inventory Control Once the initial inventory review is complete, a periodic review of the inventory should be established. This periodic inventory review will allow the list of pharmaceuticals to be updated and will aid the facility in identifying pharmaceuticals nearing expiration. Finally, this review will allow the facility to determine whether its waste reduction practices are working Stock Rotation Stock rotation is a practice to reduce expired pharmaceuticals. During the periodic inventory review, any short-dated pharmaceuticals are redistributed to other areas of the facility where they are needed and used immediately. DRAFT 7 August 26, 2010

12 Example: Fairfax-Northern Virginia Hematology-Oncology is a network of six clinics in the Northern Virginia area. The Fairfax location houses the IV admixture service, which is the central pharmaceutical distribution point for all of the other facilities. Each satellite facility receives a daily delivery of patient-specific doses prepared in most cases the day before treatment. Any pharmaceuticals that are not used are returned to the admixture site. If possible based on stability and dose, the returned pharmaceuticals are used at a later date. Example: The Walter Reed Army Medical Center in Washington, DC uses an automated dispensing system to distribute 95% of all pharmaceuticals. These machines are primarily used to ensure patient safety and for tracking pharmaceutical distribution, but the facility has found that a secondary use is for inventory control and reduction of overstocking certain pharmaceuticals. DRAFT 8 August 26, 2010

13 4. IDENTIFYING & MANAGING TYPES OF UNUSED PHARMACEUTICALS AND APPLICABLE DISPOSAL REGULATIONS Can the facility send the unused pharmaceutical back to the pharmacy for reuse? How many of the facility pharmaceuticals are hazardous waste? How should the facility dispose of controlled substances? This section will help answer these questions. After waste reduction measures are taken, EPA recommends the following general practices for managing unused pharmaceuticals: Reuse unopened pharmaceuticals where possible: either through the pharmacy or through state donation programs. Send creditable pharmaceuticals to reverse distributors. Reverse distributors are private companies that provide a service to the health care industry by keeping track of manufacturer unused pharmaceutical reimbursement policies, and thus get facilities credit for the pharmaceuticals prior to sending them off-site for disposal. Reverse distributors are registered with the Drug Enforcement Agency (DEA) and are authorized under the Controlled Substances Act to handle controlled substances that are unused, outdated, or unwanted. Under current law, reverse distributors, however, are only permitted to accept controlled substances from other DEA registrants. EPA recommends that facilities consult with their state regulatory agency to ensure compliance with all state environmental regulations when unused pharmaceuticals are sent to reverse distributors. Hospital/clinic s and doctor s controlled substance stock can be transferred to a reverse distributor for disposal. Practice proper on-site waste management and waste disposal. Consider using a contracted waste management provider for pharmaceutical waste (specialty waste hauler). A facility must meet federal and state requirements for managing unused pharmaceuticals. There are federal statutes and programs that regulate the management and disposal of unused pharmaceuticals, including: The Controlled Substances Act (CSA). Administered by the DEA, CSA provides a closed system for distributing controlled substances. As part of this system, DEA prohibits the return of controlled substances from end-users to nearly all DEA registrants, including pharmacies, hospital staff, and clinic employees. In certain cases, a full duty law-enforcement agent 5 is allowed to accept a controlled substance. Disposal of controlled substances by DEA registrants is carefully regulated to ensure that the substance is destroyed. Voluntary survey submittals, outreach meetings, and site visits indicate that disposing of controlled substances down the drain is a common practice to ensure 5 An agent is any officer or employee of any state, or any political subdivision of agency thereof, who is engaged in the enforcement of any state or local law relating to controlled substances and is duly authorized to possess controlled substances in the course of his/her official duties. 21 CFR (a)(2) DRAFT 9 August 26, 2010

14 destruction of controlled substances due to its affordability and ease. However, EPA is recommending BMPs in this guidance to reduce and avoid drain disposal. The Resource Conservation and Recovery Act (RCRA). RCRA gives EPA the authority to control hazardous waste from cradle-to-grave. This includes the generation, transportation, treatment, storage, and disposal of hazardous waste. Some pharmaceuticals may be considered RCRA hazardous wastes upon discard. As a result, health care facilities may have to comply with RCRA laws and regulations for the generation, transportation, storage, treatment, and ultimate disposal of some pharmaceuticals. Many states are authorized by EPA to implement their own hazardous waste programs in lieu of the federal RCRA program. States hazardous waste regulations may be broader or more stringent than the federal RCRA program. Therefore, health care facilities should contact their state environmental regulatory agency to ensure full compliance. The Centers for Medicare & Medicaid Services (CMS). CMS is a federal agency within the Department of Health and Human Services (HHS) that administers the Medicare and Medicaid programs. Medicare provides health insurance to elderly and disabled Americans, while Medicaid provides health insurance for low income Americans, including long-term care coverage. While Medicare is a federal program, Medicaid is a state-run program that is partly funded by federal dollars. Therefore, many Medicaid requirements are set at the state level, including regulations for management of unused pharmaceuticals. The primary role of CMS is to pay for medical products and services through the Medicaid and Medicare programs. CMS does not directly regulate pharmaceutical disposal. These policies are determined by each state s board of pharmacy and state health departments as well as any federal regulations. The Health Insurance Portability and Accountability Act (HIPAA). The Department of HHS administers HIPAA, which provides protection for the privacy of certain individually identifiable health data, such as the names of medications taken by patients. Before a patient's unused pharmaceuticals are disposed of from the health care facility, personal information on the container should be removed or obscured. This section describes how to identify and properly manage waste under these federal laws. Appendix A provides additional information on state and local requirements and programs. Note that state and local requirements may be broader or more stringent than federal requirements, so it is important to check requirements for the corresponding state and locality. Each subsection provides guidance for managing and disposing of each type of unused pharmaceutical. Table 3 at the end of this section presents EPA s recommended practices for unused pharmaceuticals by type and form. 4.1 Types of Unused Pharmaceuticals Unused pharmaceuticals include expired medications, unwanted medications (e.g., patient/resident discontinues use), and waste medication (e.g., patient/resident refuses to take or spits out). Unused pharmaceuticals are generated at health care facilities before, during, and after DRAFT 10 August 26, 2010

15 treatment, as well as during stocking activities needed to ensure sufficient materials are available for regular care. In order to properly manage unused pharmaceuticals, the facility needs to identify the types of materials on site, including: Nonwaste (i.e., reusable or returnable medications); Hazardous waste, including dual wastes (hazardous and biohazardous); Nonhazardous waste; Controlled substances; and Chemotherapeutic pharmaceuticals. Figure 1 presents a summary flowchart to assist facilities in identifying proper management methods. The flowchart provides a summary of the unused pharmaceutical types and how to manage them; a more complete explanation of how to manage unused pharmaceuticals follows the chart. 4.2 Nonwaste Medications Pharmaceutical Reuse Many health care facilities return their unused pharmaceuticals, or at least a portion of them, to the dispensing pharmacy. Upon receipt, the pharmacy determines how the unused pharmaceuticals should be managed, including: Credit and reuse of medication; Donation of medication to state programs; Credit and disposal of the unused pharmaceuticals; and Disposal of the unused pharmaceuticals. To determine whether stock unused medication can be reused or donated following return to the facility s pharmacy, ask the following questions: Is the medication in the original packaging or still in prepackaged unit doses from the pharmacy? Is the expiration date a future date at least six months out? Is the label intact? Is all the information for the medication such as type, dose, and expiration date clearly marked? Has the medication been properly stored, such as within the proper ranges for temperature, humidity, and light? Reuse of Medications When patients pay for part of the medication (and the remaining cost is covered by Medicare Part D and/or private insurance), long-term care facility pharmacies typically cannot give credit to the patient for returned medicines. They are unable to give partial credit to the patient under existing Medicare and private insurance financial tracking systems. Thus, the long-term care facility pharmacies can accept the returned medicines (excluding controlled substances), but can not resell them. DRAFT 11 August 26, 2010

17 If the facility answers yes to all the above questions, it might be able to return the unused medication to the pharmacy for reuse, or the pharmacy may be able to donate the unused medication to charitable institutions, such as programs that assist lower-income patients (state repository programs). State boards of pharmacy set policies for the return and reuse of unused pharmaceuticals. Although the policies vary by state, most allow reuse of uncontaminated medications that have been in a controlled environment, excluding controlled substances. Medications that can be reused are typically solid doses such as pills, tablets, and capsules that do not require special handling for temperature such as refrigeration. The pharmacy must remove any patient-specific information from the medication before donating. If the facility answers no to any of the above questions, the pharmacy cannot reuse the unused medication. However, the pharmacy may accept returns of pharmaceuticals for credit or for proper disposal. To receive credit from the pharmaceutical manufacturer, pharmacies send the unused medication to a reverse distributor for potential credit and eventual disposal. The reverse distributor determines which medications can receive credit from the manufacturer and then arranges for disposal of the unused and/or expired medications. Health care facilities and pharmacies should confer with state and/or local environmental agencies to ensure regulatory compliance when using reverse distributors. If the health care facility cannot return the unused medication to the pharmacy and it must be discarded, the unused medication becomes waste and the facility must follow applicable federal, state, and local laws and ordinances for waste disposal. The following subsections describe management options for unused pharmaceuticals depending on their classification. 4.3 Identifying Hazardous Vs. Nonhazardous Waste Federal hazardous waste law (the Resource Conservation and Recovery Act, or RCRA), its implementing regulations, and state regulations define hazardous wastes. Some state hazardous waste requirements may be broader or more stringent than federal requirements. The discussion in this subsection is only for reference and is not intended to be used as a substitute for RCRA itself or its implementing regulations, contained in the Code of Federal Regulations (CFR). Finally, failing to comply with RCRA can result in the initiation of enforcement actions against the facility. To be classified as a hazardous waste under RCRA, the waste must be listed in EPA regulations at 40 CFR 261 or exhibit certain characteristics. Thus, a pharmaceutical waste may be considered hazardous under RCRA if: 1. The pharmaceutical or its sole 6 active ingredient is specifically listed on The P List: Acutely Hazardous Waste (40 CFR (e)) or The U List: Discarded Commercial Chemical Products (40 CFR (f)); and/or 6 Many pharmaceuticals have more than one active ingredient. If the pharmaceutical contains an active ingredient that is on the P List or U List AND the pharmaceutical has more than one active ingredient (i.e., not sole ingredient), then that pharmaceutical waste does not meet RCRA s definition of a listed hazardous waste. However, the pharmaceutical waste may still be hazardous waste if it exhibits characteristics of hazardous waste. Although pharmaceutical waste with more than one active ingredient does not meet RCRA s definition of a listed hazardous waste, EPA recommends that health care facilities still manage the waste as RCRA hazardous waste. DRAFT 13 August 26, 2010

18 2. The waste exhibits one or more hazardous waste characteristic as defined in 40 CFR , (ignitability, corrosivity, reactivity, or toxicity). Many health care facilities also use the National Institute for Occupational Safety and Health (NIOSH) list of hazardous materials to identify additional unused pharmaceuticals that should be handled similarly to waste defined as hazardous under RCRA. Although RCRA does not require facilities to manage NIOSH listed hazardous materials the same as RCRA hazardous waste, EPA recommends that the NIOSH-listed hazardous materials be managed using RCRA guidelines as a BMP. The P and U- Listings (40 CFR (e) and (f)) A waste pharmaceutical can meet RCRA s definition of hazardous waste if the pharmaceutical (including its generic name) or the sole active ingredient of the pharmaceutical is listed on RCRA s P List or U List. P-listed and U-listed wastes fall under the hazardous waste definition included at 40 CFR , Discarded commercial chemical products, off-specification species, container residues, and spill residues thereof. Once the decision is made to discard of the unused pharmaceutical, the health care facility must identify whether or not the pharmaceutical (including its generic name) or the pharmaceutical s sole-active ingredient appears on the P-List or U-List. If the pharmaceutical (including its generic name) or its sole active ingredient is a P- or U-listed waste, then the health care facility must manage that waste pharmaceutical as a hazardous waste in accordance with all applicable federal, state and local environmental regulations 7. Table 1 lists examples of P- and U-listed commercial chemical products that have pharmaceutical uses. Table 1. Examples of Active Pharmaceutical Ingredients that are Considered Hazardous Under RCRA (P-Listed and U-Listed) Pharmaceutical Name No. Pharmaceutical Name No. P-Listed Arsenic trioxide (chemotherapy drug) P012 Phentermine (controlled substance) P046 Epinephrine (a) P042 Physostigmine P204 Nicotine P075 Physostigmine salicylate P188 Nitroglycerin (b) P081 Warfarin >0.3% P001 U-Listed Azaserine (chemotherapy drug) U015 Mitomycin C (chemotherapy drug) U010 Chloral hydrate (controlled substance) U034 Paraldehyde (controlled substance) U182 Chlorambucil (chemotherapy drug) U035 Phenacetin U187 Chloroform U044 Phenol U188 Cyclophosphamide (chemotherapy drug) U058 Reserpine U200 Daunomycin (chemotherapy drug) U059 Resorcinol U201 7 Note that the applicable regulations will depend on the quantity of waste generated each month, as described in Section DRAFT 14 August 26, 2010

19 Table 1. Examples of Active Pharmaceutical Ingredients that are Considered Hazardous Under RCRA (P-Listed and U-Listed) Pharmaceutical Name No. Pharmaceutical Name No. Dichlorodifluromethane U075 Saccharin U202 Diethylstilbestrol U089 Selenium sulfide U205 Hexachlorophene U132 Streptozotocin (chemotherapy drug) U206 Lindane U129 Trichloromonofluromethane U121 Melphalan (chemotherapy drug) U150 Uracil mustard (chemotherapy drug) U237 Mercury U151 Warfarin <0.3% U248 Source: Practice Greenhealth Managing Pharmaceutical Waste: A 10-Step Blueprint for Health Care Facilities in the United States. Revised August Accessed online at: Washington Department of Ecology Example RCRA Waste Codes for Pharmaceuticals. Accessed online at: For a complete listing of discarded commercial chemical products found on RCRA s P- and U-lists, please see 40 CFR (e) and (f), respectively, at a The Agency clarified its regulation at 40 CFR , explaining that epinephrine salts are not included in the epinephrine P042 listing; therefore, the waste epinephrine salt would be hazardous only if it exhibited one or more of the hazardous waste characteristics. Please confer with state and/or local environmental regulatory authorities to determine if this clarification is accepted in that state. (See Scope of Hazardous Waste Listing P042(Epinephrine), October 15, 2007, RCRA Online# 14778: 0c994248c239947e85256d f/2f701627eb73b2ab852573d2005e0b4f!OpenDocument). b Medicinal nitroglycerin may be excluded from the listing as it typically does not exhibit the characteristic of reactivity (for which nitroglycerin was listed). Please confer with state and/or local environmental regulatory authorities to determine if this exclusion is accepted in that state. (See Regulation of Nitroglycerin Under Revised Mixture and Derived-From Rules, March 18, 2003, RCRA Online# 14654: 0c994248c239947e85256d f/7acfec572de8897f85256d bcb!OpenDocument). RCRA Hazardous Waste Characteristics (40 CFR ) If it is determined that the waste pharmaceutical is not a listed hazardous waste, then the health care facility must determine if that waste pharmaceutical meets one of RCRA s hazardous waste characteristics. The generator of the waste can either use a standardized test method or apply general knowledge of the waste s properties in making this determination. Examples of RCRA hazardous waste characteristics exhibited by pharmaceutical wastes include the following 8 : Ignitability (D001): the presence of a flammable solvent is the most common reason pharmaceuticals meet this characteristic. For alcohol, RCRA sets a threshold limit of 24% (i.e., if the formulation contains more than 24% alcohol, then the waste is considered hazardous waste). Strong oxidizers, such as silver nitrate and potassium permanganate, in pharmaceutical formulations may also meet the definition of ignitability. 8 Source: Healthcare Environmental Resources Center, Pharmaceutical Wastes in Health Care Facilities. Accessed online at: DRAFT 15 August 26, 2010

20 Corrosivity (D002): applies to strong acids (ph 2) or strong bases (ph 12.5). In pharmaceutical compounding, glacial acetic acid and concentrated sodium hydroxide might be used. Their wastes are corrosive and thus considered hazardous. Reactivity (D003): nitroglycerin, a P-listed hazardous waste, would fall into this category if used in bulk. However, dosage forms typically do not exhibit characteristics of reactivity 9 : Toxicity (D004 to D043): The toxicity characteristic (TC) identifies wastes that are likely to leach concentrations of any one of 40 different toxic chemicals in amounts above the specified regulatory levels. Examples of TC chemicals/heavy metals that have pharmaceutical uses and their toxicity threshold levels are: Arsenic (D004): 5.0 mg/l; Barium (D005): mg/l; Cadmium (D006): 1.0 mg/l; Chloroform (D022): 6.0 mg/l; Chromium (D007): 5.0 mg/l; m-cresol (D024): 200 mg/l; Lindane (D013): 0.4 mg/l; Mercury (D009): 0.2 mg/l; Selenium (D010): 1.0 mg/l; and Silver (D011): 5.0 mg/l Requirements for Managing Hazardous Waste Any facility that generates a hazardous pharmaceutical waste is subject to the RCRA generator regulations at 40 CFR Under the federal program there are three RCRA hazardous waste generator categories, and the extent of the requirements for each generator category is defined by the amount of hazardous waste generated in a calendar month. A facility that generates 1000 kilograms (kg) or more of hazardous waste in a month, or greater than 1 kg of acute (P list) hazardous waste in a month is a large quantity generator (LQG). LQGs are subject to the full extent of the RCRA generator regulations (see 40 CFR 262). For example, LQGs must: Obtain an EPA identification number; Can store waste for only 90 days (accumulation requirement) or otherwise obtain a RCRA permit; Meet manifest and reporting requirements; and Comply with certain training requirements. 9 If a listed hazardous waste is listed solely because it exhibits the characteristics of ignitability, corrosivity and/or reactivity, and the waste at its point of generation no longer exhibits the characteristic for which it was listed, then it is not a hazardous waste (66 FR 27286, May 16, 2001). Since local and state regulations may be broader or more stringent than the federal regulations, EPA recommends the regulated community contact their local regulatory authorities to determine if this exemption applies in their states. 10 For more information regarding the various federal RCRA generator requirements, please see the following links: and DRAFT 16 August 26, 2010

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ARKANSAS Downloaded January 2011 302 GENERAL ADMINISTRATION 302.11 Pharmacies operated in nursing homes shall be operated in compliance with Arkansas laws and shall be subject to inspection by personnel